READY FOR 

October 21, 2015 

U.S. Department ofTransportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

-· 

Dan Q Pham, P.E. 

Principal Engineer 

·AlertS International LLC 

4302 Hollywood Blvd, #303 

Hollywood, FL 33021 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 

C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 

91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Application: FAA-2015-0117 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, J & M 

Underground Engineering Corp (JMUEC), a leading contractor in the South Florida area and an operator of a small 

Unmanned Aircraft System (sUAS) for aerial video and photo imaging, seeks an exemption from the Federal 

Aviation Regulations (FARs) to allow commercial operations of its sUAS, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of small, unmanned and 

relatively inexpensive sUAS under controlled conditions in airspace that is limited, predetermined and controlled 

as to help JMUEC's Engineering and Marketing teams capture videos/images for review, analysis and use of its own 

projects and for its clients. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to " ... establish requirements for the safe operation of 

such aircraft systems in the national airspace system." Section 333(c) of the Reform Act. 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81 

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, telephone 

number, or e-mail address; 

J & M Underground Engineering Corp 

Attn: Joseph M LoBue 

PO Box 163109 Miami, FL 33116 

(305) 345-4002 

joey@downrite.com 

(b) The specific section or sections of 14 C.F.R. from which JMUEC seeks an exemption 

• 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates 

• 45.23- Display of marks; general 

• 61.113- Private pilot privileges and limitations: Pilot in command 

• 91.103- Preflight Actions 

• 91.105- Flight crewmembers at stations 

• 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

• 91.119- Minimum safe altitudes: General 

• 91.121- Altimeter settings 

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J&M Underground Engineering Corp- Request for 333 Exemption 

• 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

• 91.203 -Civil aircraft: certification required 

• 91.405- Maintenance required 

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, and alteration 

• 91.409 -Inspections 

• 91.417- Maintenance records 

(c) The extent of relief JMUEC seeks, and the reason JMUEC seeks the relief 

JMUEC seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent to operate 

small UASs to record aerial photography and videography: 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of 

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which 

types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light 

of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national 

airspace system". 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its 

terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from 

the requirement that all civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or 

(b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public 

interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

14 C.F.R. 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates 

JMUEC seeks exemption from 14 C.F.R. 21, Subpart H which states the certification procedures for products and 

parts as well as airworthiness certificates. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, 

carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area as set out in the JMUEC's Field Operations Manual (Manual). Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant 

to the Manual's requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will 

have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in 

connection with motion picture and television production, provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS, due to their size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 

JMUEC has developed its own procedures and protocols to promote and provide safe flying experiences for its 

PIC(s) which can be viewed in section (e) of this petition. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's requirements, 

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J&M Underground Engineering Corp- Request for 333 Exemption 

and under the requirements and in compliance with local public safety requirements, to provide security for the 

area of operation. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

JMUEC seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. Specifically, section 45.23 

states, "(a) each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter 

"N" (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter 

used in the marks displayed must also be a Roman capital letter (b) when marks include only the Roman capital 

letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable". 

JMUEC will need exemption from this regulation due to the small size of the aircraft and that there is no cabin, 

cockpit, or pilot station for the aircraft. The words "Experimental" has been placed on the fuselage in compliance 

with §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the UAS as 

"Experimental." JMUEC will also register each aircraft in operations with a certified "N" number as required. The 

FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

JMUEC seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and limitations for the Pilot 

in command (PIC). 

JMUEC is seeking exemption from this regulation, because JMUEC believes that there is inconclusive evidence that 

only a person with a private pilot certificate can successfully maneuver a sUAS without first hand flight experience 

with the particular sUAS. In fact, having a private pilot license does not automatically ensure competence at flying 

an sUAS in 3'd person view as required to properly operate an sUAS within the required line of sight. However, we 

believe that the PIC and our FOVO (Field Operation Visual Observer) must be able to understand and correctly 

interact with the general aviation community. Therefore, we believe our own flight training with the sUAS will be 

more than satisfactory. Our PIC and FOVO will be both certified in Ground School equivalent training to be able to 

properly interact with General Aviation protocols. They will also actively pursue at minimum a sport pilot's license 

(or equivalent accepted) as well as have the necessary medical qualifications. 

14 C.F.R. 91.103- Preflight Actions 

JMUEC seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight. This information must include: (a) For a 

flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, 

alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in 

command has been advised by ATC; actions, including reviewing weather, flight battery requirements, landing and 

takeoff distances, and aircraft performance data before starting a flight. 

JMUEC will be operating its sUAS in VFR. Its Manual already includes preflight procedures directly pertaining to its 

sUAS which includes an equipment checklist as well preplanning details regarding weather conditions, review of 

any possible flight path of general aviation, its mission flight path and weather conditions amongst other 

parameters required to complete the mission. 

14 C.F.R. 91.105- Flight crewmembers at stations 

JMUEC seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. Specifically, 

91.105 states "(a) During takeoff and landing, and while en route, each required flight crewmember shall (1) Be at 

the crewmember station unless the absence is necessary to perform duties in connection with the operation of the 

aircraft or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember 

station. (b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, 

keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply 

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J&M Underground Engineering Corp- Request for 333 Exemption 

if (1) The seat at the crewmember's station is not equipped with a shoulder harness; or (2) The crewmember 

would be unable to perform required duties with the shoulder harness fastened. 

JMUEC will need exemption from this regulation due to the fact that its sUAS will not have a flight crew or crew 

stations other than the PIC and a FOVO. The PIC, not being in the aircraft, therefore will also not have to be 

restrained into a seat via shoulder harness or safety belt at the time of the flight. 

14 C.F.R. 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

JMUEC seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrument flight, and 

certain flight tests. Specifically, 91.109 states "(a) No person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, 

instrument flight instruction may be given in an airplane that is equipped with a single, functioning throw over 

control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when (1) The instructor has 

determined that the flight can be conducted safely; and (2) The person manipulating the controls has at least a 

private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, 

functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls may 

be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable 

rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot 

in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command of the 

airplane, meets the requirements of §61.195(b), and has logged at least 25 hours of pilot-in-command flight time 

in the make and model of airplane; and (4) The pilot in command and the instructor have determined the flight can 

be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless (1) The other 

control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class 

ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of 

the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) 

Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. 

However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, 

functioning, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when (i) The 

safety pilot has determined that the flight can be conducted safely; and (ii) The person manipulating the controls 

has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil 

aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that 

certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being 

checked, is fully qualified to act as pilot in command of the aircraft". Again, except when necessary for takeoff or 

landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a 

power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over 

congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over 

other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface- (1) A helicopter may be operated at less than 

the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered 

parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) 

of this section (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating-(1) Below 18,000 feet MSL, 

to-(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a 

radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) 

At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is determined by the atmospheric 

pressure in the area of operation as shown in the following table: 

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J&M Underground Engineering Corp- Request for 333 Exemption 

JMUEC believes that there is inconclusive evidence that only a person with a private pilot certificate or license can 

successfully maneuver or train someone to use an sUAS without first hand flight experience with the particular 

sUAS. Flying in 3'd person orientation requires built-up experience in that form of flying for many years. 

Therefore, JMUEC believe its own flight training, pilot protocols and first hand experiences with the sUAS as laid 

out in its Manual meets and exceeds the requirements necessary to safely operate its sUAS for the tasks it 

purposes. Also, the sUAS will be operated by a remote control, which will only require a single person operator 

and dual controls for flight operation will not be necessary. 

14 C.F.R. 91.119- Minimum safe altitudes: General 

JMUEC seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. As this exemption is for a 

sUAS that is a multi-rotor helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, 

or not more than 200 above an elevated platform from which aerial imaging is planned, an exemption may be 

needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the 

sUAS will never operate at higher than 400 AGL. It will however be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location 

where it is operated. No flight will be taken without the permission of local officials, if applicable. All flights will be 

over property owned (or being developed by JMUEC so no separate property owner consent is required. Because 

JMUEC is the owner or developer of the properties where operations will occur, all affected individuals will be 

aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft operating at 

or below 500 AGL in the movie industry. In addition, the low-altitude operations of the sUAS will ensure separation 

between these small- UAS operations and the operations of conventional aircraft that must comply with Section 

91.119. 

14 C.F.R. 91.121- Altimeter settings 

JMUEC seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowest usable flight level 

since sUAS multi-rotor operations will be within this ground to low-altitude airspace. 

C.F.R. 91.121 states, 

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.41 through 28.92 190 

28.91 through 28.42 195 

28.41 through 27.92 200 

27.91 through 27.42 205 

27.41 through 26.92 210 

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall 

take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified 

below, according to the current reported altimeter setting:" 

Current altimeter setting Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

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J&M Underground Engineering Corp- Request for 333 Exemption 

I 27.41 through 26.92 13,000 

JMUEC sUAS uses both GPS altitude and barometric sensors and relays that information to our ground station. 

However, this data is used help the sUAS to automatically maintain position hold at the required elevation and 

therefore this code is not pertinent the general functionality of this sUAS. 

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

JMUEC seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight in VFR conditions. 

Specifically, 91.151 states "(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 20 minutes". 

JMUEC sUAS has a typical mission time of less than 15 minutes with maximum flight time of 20 minutes per flight. 

Since this amount is less than the 30-minute reserve minimum, this reserve minimum would not even make sense 

in allowing the sUAS a chance to fly. According to JMUEC's Manual under "In-Flight" section, the PIC is instructed 

to maintain flight until battery power reaches 30%, or 151 level warning. At this level, landing procedures will be 

initiated and the PIC will safely land the craft at the take off location. As a back up, once the sUAS reads 10%, 2nd 

level warning, the flight control system automatically take over and initiates safe landing sequence. JMUEC policy 

outlined in its Manual achieves satisfactory safety standards. 

JMUEC believes that an appropriate and current airworthiness certificate would not be necessary to fly a sUAS 

given the size of the aircraft and the necessary level of skill needed to operate the aircraft. Before putting in to 

service, each of its sUAS goes through its own airworthiness procedures of minimum test flight and reliability 

checks. Also, its sUAS are recalibrated at the site location before each flight to ensure that all systems functions as 

designed. JMUEC seeks exemption from this regulation because it believes this rule was not meant for a sUAS and 

operators. 

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 

JMUEC seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses required aircraft 

maintenance, operation after maintenance, preventive maintenance, rebuilding, or alteration, inspections, and 

maintenance records. In the JMUEC Manual, maintenance and inspection procedures have been established for 

the aircraft. JMUEC believes these regulations are meant for manned operated aircrafts and not unmanned 

systems, therefore making them unnecessary. Nevertheless, we seek an exemption from any such specific 

provisions to the extent FAA finds it necessary to grant this request. 

(d) The reasons why granting JMUEC request would be in the public interest; that is, how it would benefit the 

public as a whole. 

JMUEC use of a sUAS can assist in making tasks safer and minimize human exposure to being at dangerous 

elevations. JMUEC sUAS usage in the aerial photography and cinematography will also reduce the time as well as 

save fuel required to capture the needed scenes as compared to conventional helicopters or airplanes. Ultimately, 

the result is quick completion of task and reduction of dangerous elevation perspective needs. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which JMUEC seeks exemption. JMUEC's 

Manual will provide a level of safety that exceeds the level of safety required by the FAA for its use on sUAS. The 

following are JM UEC safety procedures, features, regulations, and operating specifications for its sUAS: 

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J&M Underground Engineering Corp- Request for 333 Exemption 

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Our staff shall include at minimum of an approved certification equivalent of a recreational flight 

certificate and ground school certification or FAA certified certificate of safe sUAS operations when 

developed. 

During operations at minimum, we will have a Pilot In Charge (PIC) and a Flight Operations Visual 

Observer (FOVO) certified under safe operations protocols. 

The flight area of the sUAS will be observed for best take off and landing locations. Desired conditions 

include: flat and level surfaces clear of debris, at least 15ft from power lines and structures, and a 

minimum distance of 12ft from the PIC and observers. 

The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all flights . 

Flights must take place during good weather conditions with no rain, low laying clouds, or heavy winds. All 

flights will take place during daylight hours with no night flights. 

The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being designated 

working flights. 

All batteries must be charged completely before each flight and each flight must end when the battery 

has a 30% power level remaining. 

A visual safety inspection will occur before each flight, testing propeller tightness, security mount of 

camera/detection equipment, remote range test, and proper safety equipment is adorned to PIC and 

FOVO. 

The sUAS will be typically flown under a height of 200ft AGL but no more than 500ft AGL. 

No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight 

so as to ensure that the sUAS is in a condition for safe flight operation and in a configuration appropriate 

for the purpose ofthe intended flight. 

If there is more than just an operator at a site during a flight, the PIC operator and observer or FOVO will 

maintain two-way communication with each other during all operations; if unable to maintain two-way 

communications, or if any condition occurs that may otherwise cause the operation to be unsafe, the 

operator will immediately conclude the operation. 

If the communication link is lost, the sUAS will go into fail-safe mode and safely descend to its designated 

home-point location. If the communication link is reconnected during fail-safe mode, control of the sUAS 

can be regained before landing occurs at the home-point location. 

There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk of explosion 

if a crash occurs with the sUAS. 

The sUAS will feature a built in compass that will be recalibrated at every site to maintain accurate 

directional readings and help in keeping the sUAS stable during flights. 

The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum of 6 

satellites will activate the Ready to Fly status. As well as full auto-pilot return-to-home feature. 

The aircrafts to be operated will include: the DJI lnspire1 with a wheelbase of just under GOOmm and less 

than 7 lbs flying weight for medium lift as well as a DJI Phantom (Vision+ and Professional) aircraft with a 

wheelbase of 350mm and less than 3 lbs flying weight for light lift. Also, any new developed craft will be 

submitted to FAA for airworthiness approval before it can be used in operation. 

The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 1.5m 

respectfully. With a maximum wind resistance of 18mph. 

The aircraft runs off a high quality Li-Po battery . 

A NOT AM will be issued between 48 and 72 hours before flight is to occur and will be coordinated with 

the applicable FSDO. 

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the exemption; 

and (2) A brief description of the nature of the exemption you seek 

Petitioner: J&M Underground Engineering Corp. 

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 

91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 

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J&M Underground Engineering Corp- Request for 333 Exemption 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21 Subpart H; 45.23(b); 

61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 

91.417 to perform aerial photography and videography subject to operating procedures that meet or exceed those 

that FAA requires. 

(g) Any additional information, views or arguments available to support your request 

Please see the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United States, the reason why you need 

to do so 

The Operations described in this exemption request will be conducted wholly within the United States. 

Attached hereto, and submitted as a confidential document, is JMUEC's Field Operations Manual. We respectfully 

submit that good cause exists so that this confidential manual does not need to be published in the Federal 

Register. 

Since I will continue to be an adviser to JMUEC, please do not hesitate to call or contact me via email at 

dan@alertSintl.com if you have any questions or concerns. 

Respectfully submitted, 

Dan Q Pham, P.E. 

Principal Engineer 

AlertS International, LLC 

4302 Hollywood Blvd, #303 

Hollywood, FL 33021 

954-918-3888 

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